LEGAL NOTICE

Personal Data Protection Policy

Bonett Locarno Pumarejo Abogados S.A.S. · Version 6.0 · Effective from July 25, 2026

At Bonett Locarno Pumarejo Abogados we understand that trust is the foundation of every legal relationship. This document explains, in clear terms, how we collect, use, protect and retain the personal data of those who visit us, write to us, or entrust us with a legal matter, in compliance with Colombian Law 1581 of 2012, Decree 1074 of 2015 and related regulations.

1. Who is responsible for your data?

Bonett Locarno Pumarejo Abogados S.A.S. is the entity responsible for processing personal data collected through bonettlocarnopumarejo.com, our contact forms, email, phone lines and other service channels. For any questions about this policy, you may write to us at contacto@bonettlocarnopumarejo.com.

2. Purpose and scope

This policy governs how we collect, store, use, circulate and, where applicable, delete personal data, guaranteeing data subjects the effective exercise of the rights the law grants them: to know, update, rectify and delete their information, and to revoke authorization given. It applies to website visitors, people who send inquiries, current and prospective clients, counterparts, attorneys-in-fact, witnesses, experts, suppliers and other third parties connected to the matters we handle, including those of a corporate, civil, family, labor, tax and litigation nature.

Sending a message through the site allows for a preliminary evaluation of the contact, but does not by itself constitute an attorney-client relationship. When that relationship is formalized, the information shared will also be protected by the duty of confidentiality and professional secrecy inherent to the practice of law.

3. Principles we apply

We process personal data in accordance with the principles of legality, purpose, freedom, accuracy, transparency, restricted access, security and confidentiality. In practice, this means we only collect the information necessary for the stated purpose, that we act with your authorization except for legal exceptions, that we keep data updated and accurate, and that we limit access to those who genuinely need it to handle your matter.

4. What information we may collect

Depending on the channel and nature of your inquiry, we may process: your name and contact details (email, phone); the city you write from; the content of your message or description of the matter; corporate, contractual or financial information relevant to business, civil or family advice; procedural dates and terms; documents you submit yourself; billing data when a contractual relationship exists; and technical browsing information (IP address, device, browser, pages visited) collected for site security and functioning purposes. Our public form requests only what is essential to identify and respond to your initial contact.

5. Source of the information

Data may come directly from you — through our form, email or a meeting —, from duly authorized representatives or attorneys-in-fact, from documents or files related to your matter, from judicial or administrative authorities, or from technical browsing records necessary for site security.

6. What we use your data for

Website inquiries. To receive, organize and respond to your message; contact you through the indicated channel; preliminarily identify the subject matter and urgency (corporate, civil, tax, labor or other); check for potential conflicts of interest; coordinate a meeting; and prepare a services proposal.

Provision of legal services. Once a professional relationship is formalized: to structure the legal strategy; draft contracts, opinions, claims or appeals; represent you before judicial, administrative or private authorities; manage fees and billing; and keep a record of instructions and actions.

Suppliers and partners. To evaluate and engage suppliers, manage payments and verify compliance with contractual obligations.

Site functioning and security. To detect unauthorized access, generate aggregate browsing statistics and improve the site experience.

Informational communications. Sending legal publications, newsletters or industry updates requires specific, optional authorization; its absence does not affect handling of your inquiry or the provision of contracted services.

7. Authorization

Except for legal exceptions, processing your data requires your prior, express and informed authorization, which may be given in writing, through electronic means, or any unequivocal conduct that establishes your will. We keep evidence of the mechanism, the date, and the accepted text. A pre-checked box or silence do not constitute valid authorization.

Authorization is not required when information is requested by an authority exercising its legal functions, when the data is of a public nature, in a medical or health emergency, or where the law expressly provides an exception.

8. Sensitive data and minors

Our public form is not designed to receive sensitive data (health, sex life, religious or political beliefs, biometric data) nor information about children or adolescents. If your matter requires processing this kind of data — for example, in family or estate litigation — we will inform you and request the corresponding specific authorization, applying reinforced security and restricted-access measures.

9. Cookies and browsing

The site may use cookies and local storage strictly necessary for its technical functioning and security. If we enable analytics or advertising tools in the future, they will only be activated with your consent, which you may change at any time.

10. Who we may share your information with

We may share data with suppliers acting on our behalf — web hosting, email, IT security, accounting —, who are obligated to maintain confidentiality and apply adequate security measures. If a supplier is located outside Colombia, the transfer will be subject to the contractual instruments the law requires. We do not sell or share your information for commercial purposes unrelated to providing our services.

11. Your rights as a data subject

You have the right to know, update and rectify your data; request proof of the authorization given; be informed about the use given to your information; file inquiries and complaints; request deletion of your data when appropriate; revoke your authorization; and file complaints with Colombia's Superintendency of Industry and Commerce once direct proceedings with us are exhausted. These rights may be exercised directly, through your representative or attorney-in-fact, or through your duly accredited successors.

12. How to exercise your rights

Write to us at contacto@bonettlocarnopumarejo.com with "Personal data protection" in the subject line, along with your name, ID, a clear description of your request and any supporting documents. Inquiries will be answered within ten (10) business days of receipt; complaints, within fifteen (15) business days, subject to an extension notified within the terms the law allows.

13. Information security

We adopt reasonable administrative, human and technological measures to prevent loss, alteration, unauthorized access or misuse of your data. Access to your information is limited to those who need it to handle your matter or provide the contracted service. No system offers absolute security; in the event of an incident, we will act with the diligence and notifications the law requires.

14. Data retention

We retain personal data for as long as necessary to fulfill the stated purposes and the associated legal, contractual, accounting or professional obligations — including applicable statutes of limitation for each matter. Once that period ends, the information will be deleted or anonymized, unless there is a legal obligation to retain it.

15. Changes to this policy

We may update this policy to reflect regulatory, technological or service changes. Substantial modifications will be published on this same page, indicating the date of the last update. When a change materially affects the authorized purposes, we will request new authorization when necessary.

Last updated: July 25, 2026.